David Holland, Chief Inspector and IPA Money Laundering Reporting Officer

IPA Insolvency Practitioner newsletter AML Digest, December 2023

The IPA has recently received a couple of enquiries via our AML helpline email (aml@ipa.uk.com) where smaller firms are being asked to consider taking on appointments that involve businesses with links to Russia.

The firms who contacted the IPA had recognised the significant risk and were flagging the contacts with the IPA, but this is an indication that businesses looking to avoid sanctions and issues regarding Russian links are looking at smaller firms in the misguided belief that compliance with regulations is lower than in larger firms.

With the recent alert from the NCA on the increased use of gold to avoid sanctions, the risks regarding Russian & Belarussian companies remains high and firms should remain alert.

Members will have recently completed their licence and membership renewals for 2024. As part of the renewal process, the IPA required a copy of the Regulation 18 firm wide risk assessment and early in 2024, the IPA will be carrying out a ‘dip-sample’ of approx. 10% of our supervised firms to ensure that the assessments are compliant with Reg 18. If you are contacted regarding updates required to your risk assessment, please act quickly to amend and update to ensure that you can evidence proper compliance with the regulation.

The IPA have also requested details on BOOMs (Benefical Owner, Officer or Manager) for the 2024 renewals. The IPA is collating details of BOOMs for firms we supervise and further details on BOOMs can be found in the newsletter.

Finally, the IPA held the first AML & Fraud Conference specifically tailored to insolvency in September at the ICC in Birmingham. The conference had over 130 attendees and the feedback on the programme and the need for the conference to assist members with compliance in this area means that the IPA will be holding the second AML & Fraud conference in 2024.